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In re Borrelli

United States District Court, Ninth Circuit

November 6, 2013

IN RE EX PARTE APPLICATION OF COSIMO BORRELLI and G. JACQUELINE FANGONIL WALSH, JOINT AND SEVERAL LIQUIDATORS OF GALLERIA (HONG KONG) LIMITED (IN COMPULSORY LIQUIDATION), FOR JUDICIAL ASSISTANCE PURSUANT TO 28 U.S.C. § 1782, Applicants.

STROOCK & STROOCK & LAVAN LLP DANIEL A. ROZANSKY, (State Bar No. 161647) Los Angeles, CA, Attorneys for COSIMO BORRELLI and G. JACQUELINE FANGONIL WALSH, JOINT AND SEVERAL LIQUIDATORS OF GALLERIA (HONG KONG) LIMITED (IN COMPULSORY LIQUIDATION)

McKOOL SMITH HENNIGAN, P.C. KIRK D. DILLMAN (State Bar No. 110486) Los Angeles, California, Attorneys for DBS BANK LIMITED, LOS ANGELES AGENCY.

ORDER GRANTING STIPULATION AND AGREED PROTECTIVE ORDER

CARLA M. WOEHRLE, District Judge.

[PROPOSED] ORDER

Upon the Stipulation among Cosimo Borrelli and G. Jacqueline Fangonil Walsh, in their capacity as Joint and Several Liquidators (in such capacity, the "Liquidators") of Galleria (Hong Kong) Limited (In Compulsory Liquidation) ("GHK"), and DBS Bank Limited, Los Angeles Agency ("DBS LA"), by and through their respective undersigned counsel, dated October 30, 2013, and good cause appearing therefore,

IT IS SO ORDERED THAT:

1. This Order shall govern the disclosure and use by the parties of all documents, testimony, exhibits, electronically stored information ("ESI"), and any other materials and information produced or provided by the DBS LA (collectively, the "Discovery Materials") in response to subpoenas served by the Liquidators in the above-captioned case (the "Case").

2. All Discovery Materials produced or disclosed in connection with this Case shall be used solely for the purpose of assisting the Liquidators in performing their legal obligations as Liquidators pursuant to the Order of the High Court of the Hong Kong Special Administrative Region on July 23, 2010 in connection with the investigation of GHK's assets, affairs, rights, obligations or liabilities, and the identification and realization of all assets and claims of GHK (collectively, "GHK Proceedings").

3. DBS LA may, subject to the provisions of this Order, designate as "Confidential" any Discovery Materials that DBS LA in good faith believes contains any competitively sensitive or proprietary information, such as trade secrets, financial, or other commercial information of a non-public nature, information protected by the right or privacy and/or any applicable privilege, or any other sensitive information which may be subject to a protective order under Fed.R.Civ.P. 26(c)(1).

4. Discovery Materials designated "Confidential" shall be referred to herein as "Confidential Discovery Material." No designation of Confidential Discovery Material shall be effective unless there is placed or affixed on each page of such material (in such manner as will not interfere with the legibility thereof) a "CONFIDENTIAL" notice or the equivalent, or, in the case of depositions, as set forth in paragraph 6 below. ESI designated "Confidential" shall be so designated by including such notice in the body of the electronic document or by affixing a stamp with such notice on the medium (including but not limited to tapes, CDs, DVDs, hard drives and flash drives) on which the electronic data is stored before copies are delivered to the Liquidators. Print-outs or production onto a reviewable electronic platform of any such ESI designated as Confidential Discovery Material shall also be treated as Confidential Discovery Material in accordance with the terms of this Order, and when printing out or producing the Confidential Discovery Material the Liquidators shall mark the data in its reproduced format in accordance with this paragraph 4.

5. The designation of any Discovery Materials as Confidential is not intended to and shall not be construed as an admission that such Discovery Material is relevant, not subject to an applicable privilege or protection, admissible, or reasonably calculated to lead to the discovery of admissible evidence.

6. DBS LA may, on the record of a deposition, or within ten calendar days after receipt of the transcript of such deposition, designate any portion or portions of the deposition as "Confidential" under the terms of this Order. Until such time period expires without any such designation having been made, the entire deposition transcript shall be treated as "Confidential" unless otherwise specified in writing or on the record of the deposition by DBS LA. All copies of deposition transcripts that contain material designated as Confidential Discovery Material shall be prominently marked "Confidential" on the cover thereof. Objections to the designation of Confidential Discovery Material under this paragraph shall be governed by the procedure set forth in paragraph 11 below.

7. Except upon the prior written consent of DBS LA or order of the Court, the Liquidators shall not disclose, summarize or otherwise make available to anyone the Confidential ...


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